Jon D. Feldhammer

There's a reason you haven't heard of Jon's toughest cases. During his years as a senior IRS trial attorney, Jon gained a unique understanding of IRS perspectives and procedures. He speaks their language and knows how to work within the system to deescalate or get the IRS to walk away. The IRS team knows Jon to be as knowledgeable as he is fierce, and skilled at every stage of a tax dispute, including Examination, Appeals and litigation. This extraordinary combination has enabled Jon to quickly and quietly resolve hundreds of complex, high-stakes tax matters before the IRS, as well as the California Franchise Tax Board (FTB) and other state agencies.

Moreover, as someone who represents individuals and public companies, Jon's clients receive the best of both worlds: a hands-on and personalized approach, along with incredibly sophisticated counsel. He helps clients of both types navigate challenging tax environments involving income, estate and gift, employment and international tax issues. He also utilizes his first-hand knowledge of the IRS to help clients comply with new tax rules and correct previous mistakes. When proactive compliance measures are not possible, Jon litigates international and domestic tax controversies before the U.S. District Court, U.S. Tax Court and California Superior Court.

• Represented corporate and partnership clients before the IRS Exam and IRS Appeals involving section 48 investment tax credit (“ITC”) challenges with resolutions including no-changes and settlements at significantly reduced adjustments.
• Negotiated favorable settlements for corporate clients with IRS Exam regarding meals provided to employees.
• Successfully resolved partnership cases including disguised sales, at-risk rules, and disproportionate distributions.
• Successfully resolved individual cases involving charitable deductions and assignment of income arguments before IRS Appeals.
• Litigated estate and gift taxes issues including valuation, split-dollar arrangements, and family limited partnerships (“FLPs”).
• Litigated FBAR penalties.
• Litigated multiple cases involving bad debt and worthless securities.

Selected as an "Outstanding Volunteer" by Justice & Diversity Center of the Bar Association of San Francisco (JDC), 2019-2023

Recognized in The Best Lawyers in America (Woodward White, Inc.) for Tax Litigation and Controversy, 2018-2023

J.D., Cardozo School of Law 2007
Editor in Chief, Journal of International and Comparative Law

B.A., Vassar College 2000

State Bar of California

United States District Court for the Northern District of California

United States Tax Court

San Francisco Estate Planning Council, Member

American Bar Association, Taxation and Trust and Estate Law Sections, Member

California Bar Association, Taxation, Tax Litigation, and Trust and Estate Sections, Member

The Bar Association of San Francisco, Member